Last modified: Jan 26, 2024 5:40 (UTC+08:00)

PRIVACY POLICY

The current privacy policy depicts your privacy rights in terms of gathering, use, storing, sharing, and protecting your personal data. You agree to this privacy policy by registering, accessing, or using DNBC Financial Canada Limited’s products, services, solutions, features, and technologies. If you do not agree, you should stop accessing this site or DNBC Financial Canada Limited Services immediately and refrain from further access and use of them.

Herein the following definitions will apply:

“You”, “Your”, “Yours” refers to any user of the DNBC Financial Canada Limited Site, DNBC Financial Canada Limited Account or DNBC Financial Canada Limited Services.

“We”, “Our” and “Us” refers to DNBC Financial Canada Limited.

“DNBC” means a business name of a DNBC Financial Canada Limited, a legal entity registered in Canada with MSB registration number M21756795 issued by FINTRAC. DNBC’s place of business is at Suite 1480 HSBC Building 885 West Georgia Street Vancouver, BC, Canada V6C3E8. Any references to DNBC shall refer to DNBC Financial Canada Limited.

“The Site” refers to the DNBC Site (www.dnbcgroup.com/en-caorwww.dnbcnet.com), including all its content.

“DNBC Account” means personal or business account of Clients opened with DNBC.

“DNBC Services” means access to DNBC Account allowing you to open an individual or business account and make payments inside DNBC or payouts from it, pay bills, exchange currency, and obtain any other services provided by DNBC.

DNBCnet means internet-based software app, API, and other software and technologies allowing obtaining DNBC Services.

“Data Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

ROLES AND RESPONSIBILITIES

You should be aware that by providing you with DNBC Services we act as a data controller and you may act as a data subject or as a joint data controller as a case may be. The terms “personal data”, “data subject”, “data controller” and “data processor” are used in the meaning given by the general data protection regulation (PIPEDA).

By opening the DNBC account for you, we collect your personal data, so in this case, we act as data controller, and you act as a data subject, therefore we are subject to respective rights and obligations under applicable data protection laws.

In some cases, when you are a business, you transfer to us personal data of your clients or the personal data of your officers. Insofar you and we jointly determine to process personal data for the purposes of our cooperation we and you are joint data controllers and bear several liabilities for data protection infringements. You shall warrant that you have appropriate legal grounds to collect, process, and transfer to third parties the personal data of your clients or officers. In more detail, your and our obligations and responsibilities will be allocated in the data protection agreement with you.

PRINCIPLES OF PERSONAL DATA PROCESSING

We processed your personal data in accordance with valid legal acts and the following principles:

• personal data with respect to you is processed in a lawful, honest and transparent way;
• personal data is collected for specified, clearly defined and legitimate purposes and shall not be further processed in a way incompatible with those purposes;
• personal data must be adequate, appropriate and only which is necessary for the purposes for which it is processed;
• personal data must be accurate and, if necessary, updated; all reasonable steps must be taken to ensure that personal data which is not accurate in relation to the purposes for which it is processed shall be immediately erased or corrected;
• personal data shall be kept in such a way that your identity can be determined for no longer than is necessary for the purposes for which personal data is processed;
• personal data shall be managed by applying appropriate technical or organizational measures in such a way as to ensure the proper security of personal data, including protection from unauthorized processing or processing of unauthorized data, and against accidental loss, destruction or damage.

WHAT DATA WE COLLECT

In case you access your DNBC Account, use DNBC Site, or use any of the DNBC Services, the following type of personal data might be gathered:

• Personal information, used for opening DNBC account, manage and administer DNBC Services:
  • First and last name
  • Date, country and place of birth
  • Nationality
  • Gender
  • Names, roles, and contact details of your officers, power of attorney, in case you are opening the business account.
• Contact details, used to maintain permanent communication with you, to send you legal and information notices:
  • First and last name
  • Residential address
  • Telephone number
  • Email address
• Information used for carrying out the Know Your Client (KYC) procedure and anti-money laundering (AML) checks:
  • Personal code
  • Date of birth
  • Age (year of birth)
  • Passport or other government-issued identity document
  • Your photograph
  • Documents establishing your source of funds
  • Results of KYC checks, including information collected by our service providers
  • Video identification data

When you are an entity, we collect personal code, identity card, surname, address, nationality, name, photograph, signature, number of shares held, voting rights or share capital part, data about the beneficiary of funds of the ultimate beneficial owners (natural persons who directly or indirectly own or control an entity).

• Information generated or collected in the course of providing DNBC Services, which DNBC uses to develop and improve its services.
  • Signature
  • Correspondence with DNBC and support data (telephone, chat conversations and email)
  • Your transaction data
  • DNBC site activities
• Financial information including your full bank account number and/or credit card number, IBAN number (used for payments to you and full use of DNBC Service);
• Device data (such as a type of device, operating system, IP-addresses and advertising ID’s, your location, web and mobile network data), сookies and usage data on how you use our products and services. It is used for accepting you as a customer of DNBC Account, to safeguard you from scam, fraud, and misuse of any private data you might share, to improve our services. For more details about cookies please see our Cookie Policy below.

Also, pay attention to the fact we may acquire information related to you provided by third parties like services for person verification, marketing agencies, your publicly available profile information (LinkedIn, Facebook, Twitter, Google Accounts), information related to payments to or from your accounts with us, provided by payment processing services, banks, card schemes and other financial services firms, information from fraud prevention agencies.

We do not collect any extra data but only that information that is necessary for the purpose of providing DNBC Services to you.

Please be aware that the list of information types mentioned above is not exhaustive. Additional information about you might be gathered in some other way, for instance by contacting our Customer Support hotline or taking part in surveys, etc.

SENSITIVE PERSONAL DATA

When required by AML legislation we may collect biometric information (such as facial photographs or fingerprints) of their clients for the identification purpose. Such information is defined by PIPEDA as sensitive information and can be processed only if the law requires this or the data subject has given express consent. Clients who refuse to provide such information cannot obtain DNBC Services in full. Clients may contact DNBC support to obtain information on what services may be used without providing biometrics.

We do not intentionally collect any other sensitive personal data, such as religious beliefs, health information, racial or ethnic origin etc. Nevertheless, there might be cases when information or documents data subject submits to us contain sensitive information or we can obtain it in the course of providing our services (e.g. during KYC procedure or information that follows from payment transactions of certain types). To allow us to process your sensitive personal data you will be requested to provide explicit consent by means of DNBC Account functionality or by e-mail. In some cases, we may be required to process such data for the reasons of substantial public interest, on the basis of Canada or local law.

HOW WE USE YOUR DATA

The main goal of gathering and processing your personal data is to deliver an effective, scalable, smooth, and personalized DNBC experience. Hence, personal data we collect might be used to:

• Ensure maximum DNBC Account user experience;
• Process transactions and issue relevant notifications in the most comprehensive manner;
• Settle disputes, levy charges, and resolve occurring problems;
• Prevent clients from becoming a subject to illegal activities and potential fraud;
• Improve quality of services, solutions, and incentives DNBC offers on a daily basis;
• Being able to contact you in case of emergency via one of the means available;
• Make sure the information you provide is accurate, in case discrepancies occur;
• send personalized offers of services and products, in accordance with the rules as they are described in part “Legitimate interest” of the section “Legal basis for processing” of this Privacy Policy;
• carry out regulatory checks and meet our obligations to our regulators;
• prevent and detect fraud, money laundering and other crime (such as terrorist financing and offenses involving identity theft);
• develop new services based on the collected information.

Your personal data is not used for any additional purposes not mentioned in this Privacy Policy or the contract with DNBC.

AUTOMATED DECISION-MAKING

In some cases, we may make automated decisions regarding you using your information. When you instruct us to make a payment from your account or to request payment into your account from a bank or other payment services provider, our systems (or systems provided to us by our suppliers) make an automated check for authorization and automated checks to detect an unusual transaction pattern or location of your transaction and help us to fight fraud. You are entitled to contest automated decision making by contacting us.

HOW WE PROTECT YOUR DATA

We warrant and represent that DNBC has implemented the technical and organizational security measures and technological development to ensure an appropriate level of security of personal data. Your data is protected by the means of physical, technical, and administrative resources to lower the risks of loss, misusage, unauthorized entry, disclosure, or alteration by a third party. To keep your data be safe we apply:

• Firewall and data encryption protection
• Physical authorization control system
• Surveillance facilities, video/CCTV monitor, alarm system
• Securing decentralized data processing equipment and personal computers
• User identification and authentication procedures
• Tunneling, logging, transport security
• Audit trails and documentation
• Backup procedures,

And many more things.

As DNBC is PCI DSS V3.2.1 certified, we maintain all required technology, methods and business processes to protect cardholder data, and also use such technology and methods as regards the security of your personal data.

We monitor our systems 24x7 and our staff is always ready to respond to your notifications and queries within a short time.

DNBC respects your privacy and your personal data and warrants that:

• Your data will not be disclosed to advertisers or any unauthorized third parties except as provided by this Privacy Policy;
• We keep your data and any information provided by you in confidence in accordance with the terms and conditions set in a separate agreement with DNBC;
• We will use your data only as described in this Privacy Policy;
• We will maintain appropriate administrative, technical and organizational measures to protect your personal data;
• We will notify you promptly of any suspected or actual breach of the security of your data;
• We will assist you in ensuring compliance with your duties under Canada's Protection of Personal Information and Electronic Documents Act (PIPEDA);
• We impose on our sub-contractors the same data protection obligations as set out in the contract with you.

We will notify you of any personal data breaches (including any unauthorized or accidental access) without undue delay after becoming aware of a personal data breach.

We will notify you of personal data breaches where the breach is likely to create significant risks to your rights and freedoms (including any unauthorized or accidental access) without undue delay after becoming aware of a personal data breach.

We are not obliged to give the notification to you if at least of the following conditions is fulfilled:

• We have ensured and implemented the appropriate technical and organizational security measures, for example, encryption of personal data or other measures rendering the personal data unintelligible to any person who is not authorized to access it and such measures were applied to the personal data affected by the personal data breach;
• We keep your data and any information provided by you in confidence in accordance with the terms and conditions set in a separate agreement with DNBC;
• We have taken subsequent measures which ensure that the high risk to the rights and freedoms of the data subject(s) is no longer likely to materialize;
• Giving the notification to you would involve disproportionate effort. In such a case, a public communication or other chosen measures whereby you were informed in an equally effective manner may be applied by us instead of giving a notification to you.

We immediately inform you if, in our opinion, you infringe PIPEDA protection provisions. You shall ensure the security of data you transfer to DNBC. You assume full liability for failures to meet the PIPEDA in cases when it is envisaged by this Privacy Policy or PIPEDA.

HOW WE SHARE YOUR DATA

DNBC warrants that it will not disclose your personal data to any unauthorized third party.

DNBC may share your data with DNBC’s contractors who may use such information only for the limited purpose of providing services to you and who are obligated to keep the information confidential, including without limitation:

• Card schemes, banks and payment service providers - to make you able to obtain acquiring services, money transfers and other payment services;
• Suppliers related to financial services or operations (e.g. KYC and sanctions screening, credit checking, card supply) – to provide you high-quality service, fight fraud and comply with requirements of law.
• Suppliers of analytic services – to monitor, evaluate and improve DNBC Account.
• Information generated or collected in the course of providing DNBC Services, which DNBC uses to develop and improve its services.
• It services suppliers (e.g. disaster recovery services, website hosting, data and applications hosting, software application provision and maintenance) - to ensure uninterrupted operation of DNBC Account.
• Communications services suppliers - to communicate with you and provide you with up-to-date information on the usage of DNBC Account, e.g. by SMS or e-mails.
• Customer support services - to operate our payment services platform and provide administration and customer support.

To ensure the payment process runs smoothly, some of your personal information may be shared with a company or entity you cooperate with inside DNBC. Your registration date, number of payments you have issued/received via DNBC, info whether you have an authorized control over a bank account – all that information might be shown to DNBC users you work with at the moment.

We may also transfer your personal data to our professional advisers (such as lawyers, accountants, auditors, consultants, management consultants), who are under a professional obligation to maintain confidentiality and security of personal data.

Your personal information may be shared with third parties if so required by applicable laws, regulations, instructions we must obey or in the response of valid court order or requirements of other government bodies.

In addition, we may convert your personal information into anonymous or aggregated form, in which case it will cease to be personal data.

CROSS-BORDER TRANSFERS

For the purpose to provide you with DNBC Services we can engage the third-party service providers outside Canada. In such cases personal data may be transferred outside Canada, including to the United States. Data protection laws of third countries may be different from Canada data protection laws and not guarantee adequate levels of security. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that personal data remains protected.

We use Canadian commission-approved standard contractual clauses as a legal mechanism for data transfers from Canada. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. DNBC does not participate in privacy shields at this time. Nevertheless, we rely on the Canada-US privacy shield to transfer personal information to some of our third-party service providers in the United States, where they are certified to receive such information under the privacy shield program.

When you act as a joint data controller, you shall inform your clients about risks of cross-border transfers and obtain their consent for that.

COOKIE POLICY

When you visit DNBC’s Site or DNBC Account, a small Cookie file might be placed on your computer or mobile device. We will analyze data from the Cookies and use it to improve the quality of our services, track your activities with DNBC, and keep your account safe. Any personal information that we collect and store through the use of cookies is first obtained through notice and consent. We obtain your consent by providing you with transparent notice of the use of the cookies and, to the extent described herein, providing you with the opportunity to make a choice to disable these cookies, except the session cookies. We offer certain site features, services, applications, and tools that are available only through the use of the cookies. You are always free to block, delete, or disable cookies in your browser, installed application, or device so permits. However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain site features, services, applications, or tools.

What is the cookie?

A cookie is a small text file stored in a computer’s web browser memory.

There are three main types of cookies:

Session cookies – they help you do not re-enter information and stay logged in each time you change web–pages. Session cookies are deleted automatically after you leave the site or when you close your browser.

Persistent cookies – they help us to recognize you each time you return to the DNBC Site and remember your preferences for viewing the site. Such cookies are stored on your computer until deleted by you or automatically after its expiration.

Third-party cookies - are the persistent cookies placed not by DNBC which help to gather browsing activity across numerous websites and during several sessions. Such cookies are stored on your computer until deleted by you or automatically after its expiration.

You can find out more from https://www.aboutcookies.org/

How do we use cookies?

We use cookies for the following purposes:

Authentication. When you login in DNBC Site or DNBC Account, we use cookies to remember you so you don’t have to log in each time you left the main page and navigate throughout the DNBC Site.

Fraud prevention. With help of cookies we can obtain information about security of your computer and web browser used to access to DNBC Site or DNBC Account and to detect harmful or illegal use of DNBC Services.

Settings. We can use cookies to remember your settings of the DNBC Services so you do not have to change it each time you log into DNBC Site or DNBC Account. For example, you can choose to remember payment details and associate it with your computer to make recurring payments or use language or font you prefer.

Improving DNBC Services. We use cookies to understand how we can make DNBC Site and services better. Cookies help us to know how people reach DNBC Site, detect and gather reporting on bugs; improve functionality and speed of DNBC Site and DNBC Account portal.

Marketing. From time to time we can use cookies to show you more relevant ads, e.g. to not show the same ads multiple times or recognize actions across multiple devices or browsers, etc. We reserve the right to use Google Analytics to understand how DNBC Site or DNBC Account is used by its users. You can opt-out of google analytics advertising features as described below.

What other technologies can we use?

There are other technologies used by us to track your activity on the site or DNBC Account portal.

Web beacons (web pixels) are small graphics helping to understand browsing activity, track conversion and optimize ads. These graphics files are downloaded when you visit the site or DNBC Account portal.

Local storage objects (flash cookies) are files that can be stored on your browser and can be used to detect preferences, to record the history of usage, or remember settings of the site or DNBC Account. You can block or control flash cookies at any time by modifying the settings of your browser.

Google Analytics. Google Analytics is third-party technology, which allows collecting and analyzing information about how you use the DNBC Services and web sites and creating relevant reports. Upon you have accepted the use of cookies on our Site, we may use Google Analytics. Nevertheless, you can at any time opt-out through google ads settings. Google also provides a

google analytics opt-out plug-in for the web.